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    <title>2015 (6) TMI 665 - ITAT KOLKATA</title>
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    <description>Section 40(a)(ia) disallowance for non-deduction of tax under section 194C was held to require reconsideration because the jurisdictional High Court had rejected the Merilyn Shipping view on confining the provision to amounts outstanding at year-end, so the matter was remanded for fresh decision. Verification of ROC expenses was only directed and no substantive relief survived, so the Revenue&#039;s challenge failed. Inspection, processing and rating charges for obtaining bank finance were treated as revenue expenditure because they did not create an enduring capital asset, and the deletion was upheld. The addition for alleged closing stock discrepancy against the insurance policy was also deleted for lack of supporting enquiry and factual basis.</description>
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      <title>2015 (6) TMI 665 - ITAT KOLKATA</title>
      <link>https://www.taxtmi.com/caselaws?id=260740</link>
      <description>Section 40(a)(ia) disallowance for non-deduction of tax under section 194C was held to require reconsideration because the jurisdictional High Court had rejected the Merilyn Shipping view on confining the provision to amounts outstanding at year-end, so the matter was remanded for fresh decision. Verification of ROC expenses was only directed and no substantive relief survived, so the Revenue&#039;s challenge failed. Inspection, processing and rating charges for obtaining bank finance were treated as revenue expenditure because they did not create an enduring capital asset, and the deletion was upheld. The addition for alleged closing stock discrepancy against the insurance policy was also deleted for lack of supporting enquiry and factual basis.</description>
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